UNSW Sydney

Name (Individual/Organisation)

UNSW Sydney

Responses

Q1. How could the purpose in the ARC Act be revised to reflect the current and future role of the ARC?

For example, should the ARC Act be amended to specify in legislation:
(a) the scope of research funding supported by the ARC
(b) the balance of Discovery and Linkage research programs
(c) the role of the ARC in actively shaping the research landscape in Australia
(d) any other functions?

If so, what scope, functions and role?

If not, please suggest alternative ways to clarify and define these functions.

Thank you for the opportunity to contribute to the Review of the ARC, to increase the effectiveness and efficiency of Australia’s flagship non-medical research funding agency. The effective operation of the ARC, and the broader administration of university research, are critical to the success of Australia’s research sector, and ultimately to Australia’s future prosperity.

As one of the most substantial contributors to publicly funded research in Australia, UNSW Sydney has significant engagement with the ARC as an applicant for public research funding, as a partner in the administration of that funding, and as a provider of expertise for the assessment of and decision making on funding awards.

CURRENT AND FUTURE ROLE OF THE ARC

Scope of Research Funding

The ARC plays a critical role as Australia’s primary funding body for non-medical research. There are very limited alternate funding sources for fundamental research outside of the ARC. Given this position, the Act should not become overly prescriptive on scope of funding, but maintain a level of versatility to respond to changing research priorities.

While the consultation does not request input on the funding envelope, it is important to note that the current funding envelope is insufficient for the ARC to fulfil its current and future role defined in the Act (and indeed is declining in real terms), with a significant number of the issues identified below difficult to address within its current allocation. We note that consideration to the broader question of funding for research is expected to be considered by the forthcoming Universities Accord process.

Balance of Discovery and Linkage research programs

The ARC Discovery Program plays a key role in enabling Australia’s fundamental research. The ARC must maintain, and preferably grow, Discovery funding, to a level at a minimum consistent with funding streams for fundamental research in other leading research nations.

It is critical to recognise the importance of fundamental research both for its intrinsic worth and as the source of knowledge that enables downstream translational research and commercialisation. Reassigning funding from Discovery to Linkage schemes should be limited, with translational research supported by additional allocations. To this end, a legislated balance of allocations for basic and applied research should be considered, with the dual aim of supporting both fundamental and translational research embedded in the Act.

Shaping the Research Landscape

The ARC, as the primary funding agency for non-medical research, needs to play an active role in identifying and supporting Australia’s research landscape. However, in doing so it should be led with the expertise that exists in leading research institutions both nationally and internationally. While there is a role for shaping some component of research in the national interest, the primary function of supporting fundamental and applied research should account for most of the ARC’s activities. This role should define research priorities inspired by global challenges, and provide high quality recommendations and advice on research, at both a national and potentially international level.

The ARC should ensure that a broad spread of funding is maintained across all disciplines, recognising that different subjects may require different levels and types of funding, and have their own unique research cultures.

It is also important under a translational umbrella, that the ARC actively seeks to shape the research landscape, i.e. leverage funded projects and researchers, bringing them together with each other and potential customers/end-users in industry, government and the community to secure outcomes of benefit to Australia and aligned with Australia’s national priorities.

Other Functions

Under the current legislated arrangements, there is scope for improvement to the ARC’s functions and role. Specifically, consideration should be given to whether the ARC and the nation’s research would be better served as a statutory authority under the Department of Industry Science and Resources, rather Department of Education, reporting to the responsible Minister. It would then be worth considering whether to align and coordinate Australia’s national research effort under an overarching body as happens in the UK with UKRI, covering the ARC, NHMRC, MRFF and arguably CSIRO.

Q2. Do you consider the current ARC governance model is adequate for the ARC to perform its functions?

If not, how could governance of the ARC be improved? For example, should the ARC Act be amended to incorporate a new governance model that establishes a Board on the model outlined in the consultation paper, or another model.

Please expand on your reasoning and/or provide alternative suggestions to enhance the governance, if you consider this to be important.

The current governance model of the ARC is no longer fit for purpose. The following principles should be central:
• Appointments to the Board of the ARC must be non-political, and reflect the diversity of the sector – particularly with respect to the varying scope of activities across the sector (e.g. Go8 vs regional), range of disciplines, basic vs applied research experience etc.
• the formal governance structures of the ARC should be embedded in legislation, including the introduction of an independent ARC Board or Council which reflects the Australian research community.
• The ARC board should assume the authority to appoint the CEO of the ARC, to provide strategic direction to the organisation, and to approve the award of funding as recommended by the peer review process.
• The Haldane principle should be central to the governance model of the ARC and its decision-making processes, as legislated in the UK. If Ministerial discretion is to be retained for prescribed areas, such as National Security and Safety (but explicitly not politico-cultural areas), this must be fully disclosed to Parliament on the rare occasions it is applied.

Q3. How could the Act be improved to ensure academic and research expertise is obtained and maintained to support the ARC?

How could this be done without the Act becoming overly prescriptive?

Diversity of expertise in both assessment and management is critical, particularly across the different disciplines supported by the ARC. The Act should ensure the appointment of senior academic researchers within the ARC to provide expert academic advice and balance the more bureaucratic element of the ARC’s work. Firstly, the CEO should be required to have a strong track record in both research and research management, not simply for the Minister to consider these and then discount research track record as at present. Furthermore, the Executive Director model should be retained, but bolstered through the appointment of experienced and active senior researchers.

The Act should strengthen the role of the Board relating to the appointment, performance and termination of the CEO, as well as requiring the CEO to have a strong research track record.

Q4. Should the ARC Act be amended to consolidate the pre-eminence or importance of peer review?

Please provide any specific suggestions you may have for amendment of the Act, and/or for non-legislative measures.

We support embedding the Haldane principle in the operation of the ARC. We would further support legislation limiting the discretionary ability of the decision maker to overturn decisions made under such processes to specific areas (such as National Security, Health and Safety, or similar areas, but explicitly not political/cultural) and require that such actions be reported in a transparent and timely matter. This could be achieved by requiring the responsible minister to table, in Parliament, within 15 sitting days, the reasons, evidence and advice received for each instance when such rare discretion is exercised.

Q5. Please provide suggestions on how the ARC, researchers and universities can better preserve and strengthen the social licence for public funding of research?

The ARC should be heavily involved in ensuring that the social licence for public funding of research remains current. The present approach of requiring a National Interest Test for each funded project is not an effective mechanism for achieving this aim, and should be removed.

A more effective way for the ARC to support this social licence is by better engaging with the public to help increase the understanding of the role of publicly funded research and the benefits and outcomes that have ensued over a range of timescales. This should not be limited to translational and commercial outcomes, but cover the full range of benefits, including to physical and mental health, social advancement, the arts, our understanding of the world we live in, how we are governed, and our history. This should not take the form of an Engagement and Impact Assessment, but instead involve the ARC proactively engaging with the Australian community at a significantly greater scale than it currently does.

The ARC should put effort into delivering the message that basic research has value both for its own sake (increasing human knowledge and understanding of the physical and social world is inherently a good thing) and because ‘impact’ can be unpredictable and does not necessarily follow a linear path (e.g. number theory and cryptography, WiFi, etc).

Australia’s research output, both fundamental and translational, is ultimately a significant national asset, and should be celebrated as such.

Q6. What elements of ARC processes or practices create administrative burdens and/or duplication of effort for researchers, research offices and research partners?

There is clear scope for the ARC to increase efficiency, which would benefit not only researchers and research organisations, but the ARC itself. Below we list a number of suggestions:

Pre-award

The application process is overly complex, often duplicative of effort and places a substantial administrative burden on researchers, and research offices. Particular areas of concern include:

• Requirement for Administering Organisation Statements – the combined time of our researchers, Heads of School and research officers to produce Administrative Support Statements across FT, DE and FL equates to the equivalent of nearly 15 weeks/pa of administrative burden. The budget, track record and project descriptions already incorporate the most valuable components of these statements;
• Duplication and unnecessary detail in applications, and a rejoinder process, that has limited value in assessment;
• Overlap between major application rounds, such as the recent FT and DECRA calls.

Post-award

Many post-award processes are overly and unnecessarily complicated, and can lead to substantial time lag in commencement and progress of research projects. These include:
• Requirement for all participating agreements to be executed before project commencement;
• Budget variation requests;
• Variations to funding agreements (VFAs) when CIs (other than the lead CI) change organisations;
• Completion, review and submission of ARC final reports given their current use;
• ARC EOY process;
• Partner/Participating Organisation Agreed Contribution Reports (POACR) – the format is not user friendly and often does not make sense for the actual project period;

General

• Potential foreign interference issues: responses to ARC requests specific to a project require a level of investigation with responses drawn from several areas of the University (including research, grants, enterprise and national security teams), and give the appearance of ARC running a separate vetting process in parallel to the main effort Australian universities have invested in around UFIT.

Q7. What improvements could be made:

(a) to ARC processes to promote excellence, improve agility, and better facilitate globally collaborative research and partnerships while maintaining rigour, excellence and peer review at an international standard?

(b) to the ARC Act to give effect to these process improvements, or do you suggest other means?

Please include examples of success or best practice from other countries or communities if you have direct experience of these.

Current ARC timelines are bureaucratic and not competitive with international rivals. As an example, funding of an idea under the Discovery scheme takes between 1-2 years from inception of the idea to the availability of funds, assuming the proposal is funded at the first opportunity (itself unlikely with current success rates of ~15%). In contrast, more dynamic funding ecosystems such as those in the US or UK have multiple opportunities for funding on shorter timescales, either running multiple rounds of a scheme each year, running schemes in a responsive (rolling) manner, or by supporting targeted calls which provide additional opportunities for funding in areas of high interest. The earlier move to a rolling application approach for the Linkage Scheme provides a model which could be considered for discovery research.

Other improvements to processes include:

Pre-award

• Provision of a more detailed annual grant calendar, with stability over time, would enable organisations to plan staffing profiles more effectively;
• Simplification of the grant application process, including reducing the ROPE sections and shortening/simplifying other sections to reduce applicant and peer review burden;
• The introduction of a “minimum data” deadline for applications, similar to that used by the NHMRC, would greatly assist with administrative workload management;
• Remove the rejoinder process – it is not clear that rejoinders significantly impacts outcomes, but they do involve significant effort from researchers/administering organisations to participate in this process within a short timeframe, and dramatically increase the length of the assessment process. The NHMRC’s removal of rejoinders is instructive here, and the ARC should similarly consider the value of rejoinders in their current form.

Post-award

• Simple budget variations should not require ARC approval. The responsibility should be on the CI/Administering Institution to spend the budget across a range of allowable costs while ensuring they still address the aims of the projects;
• Change of organisations by CIs other than the lead should similarly be managed by the Administering Organisation without the need for a variation;
• Introduce risk thresholds to reduce reporting burden
• All relinquished and returned unspent funds should be repurposed by the ARC for additional funding opportunities such as a high quality near-miss scheme.

General

• The ARC should identify dedicated funding for multi/bilateral funding programs in partnership with other funding agencies abroad. Australian research benefits greatly from working with global researchers and this should be appropriately resourced.

Q8. With respect to ERA and EI:

(a) Do you believe there is a need for a highly rigorous, retrospective excellence and impact assessment exercise, particularly in the absence of a link to funding?

(b) What other evaluation measures or approaches (e.g. data driven approaches) could be deployed to inform research standards and future academic capability that are relevant to all disciplines, without increasing the administrative burden?

(c) Should the ARC Act be amended to reference a research quality, engagement and impact assessment function, however conducted?

(d) If so, should that reference include the function of developing new methods in research assessment and keeping up with best practice and global insights?

UNSW recommends that the ERA & EI assessments be discontinued.

• ERA has served its purpose in focussing the nations university R&D on quality and impact.
• No other country has a national assessment system which is not used to determine institutional funding allocations.
• The multi-faceted and ever evolving nature of research quality, engagement, and impact mean that long-run retrospective assessment to generate a single rating for a discipline is flawed and provides questionable value to Australia and Australians. This is highlighted by the yawning gap in global standard between citation and peer reviewed disciplines.
• ERA & EI create huge cost and compliance burdens for both universities and the ARC, in turn diverting resources away from conducting or supporting research.
However, articulating the outcomes of funded research remains important and UNSW recommends that the ARC improves & expands final reporting for awarded grants to capture robust information on outcomes including research quality, engagement, and impact.

Need for an Impact Assessment

The national ERA & EI exercises have diminished in relevancy over the past decade with the growth of international rankings that cover a growing number of areas from overall university excellence to subject-level performance to contribution towards impact and Sustainable Development Goals. The cost of administration combined with the absence of funding links has further lessened the value proposition of a national exercise for the research community, Government, and Australians. UNSW believes that ERA & EI have served their purpose and are no longer suited to measuring research excellence, engagement, and impact. Neither ERA nor EI should continue in its current format and even substantive changes to automate and reduce administration would result in little benefit.

Other evaluation measures or approaches

Automated and semi-automated evaluation measures and approaches are available and have been used by world university rankings for over a decade. Dedicated products such as Elsevier SciVal, Clarivate InCites, and Digital Sciences Dimensions contain indicators on research quality and their output can be used to inform research standards and future academic capability. These systems have the added benefit of providing a broad range of up-to-date metrics under a variety of research classification systems to stay relevant as research fields emerge and change over time. One challenge however has been in the varying subject classifications used, and allocating individual outputs under the new FoR codes as a national system is not yet in a position to automate through AI/ML approaches.

ARC Act Assessment Function

The ARC should not be tasked with the assessment and benchmarking of universities on research quality, engagement, and impact, and therefore the ARC Act does not need to be amended. The ARC is but one of several public funders of research, and if this was to be pursued downstream it should fall to a body overseeing all publicly funded research, covering the NHMRC, ARC and MRFF, if not CSIRO.

Q9. With respect to the ARC’s capability to evaluate research excellence and impact:

(a) How can the ARC best use its expertise and capability in evaluating the outcomes and benefits of research to demonstrate the ongoing value and excellence of Australian research in different disciplines and/or in response to perceived problems?

(b) What elements would be important so that such a capability could inform potential collaborators and end-users, share best practice, and identify national gaps and opportunities?

(c) Would a data-driven methodology assist in fulfilling this purpose?

Using the ARCs Research Evaluation Expertise

Harnessing the capacity of the ARC to analyses the large store of data it holds on the outputs and impact of the work it funds is critical to enhancing the social licence underpinning publicly funded research. The approach should make use of existing data, and not seek to add additional reporting requirements unless there was a clear and beneficial reason for doing so. Care must be taken to ensure that issues identified in existing assessments are avoided – single numerical rankings are of little value, administrative burden should be weighed against the benefit of data collection (which should be automated as much as possible), and a comprehensive plan for the public understanding and support for the benefits and value of excellent research should drive the process.

Elements for Research Evaluation

The most effective ways to ensure that the ARC can identify national gaps and opportunities in research is to ensure that the Board and Executive Directors are senior researchers with a breadth of expertise. They would be best positioned to identify the information required to ensure the ARC’s programs provided coverage of potential research gaps. In addition, ensuring that the ARC retains broad programs that enable submissions from all non-medical research areas should ensure that the research community is able to place opportunistic research in front of their peers for consideration. As noted above, the speed of the ARC review processes is currently a significant factor which limits the competitiveness of opportunistic research in a global context.

Data Driven Methodology

A data driven methodology is critical if this process is to enhance Australia’s research capacity rather than add additional reporting loads which reduce research capacity. As noted above, a wide range of automated and semi-automated research evaluation tools are available. It is important to note, however, that much deeper analysis, contextualisation and communication of any data is necessary before it can be sued effectively for any of the above purposes.

Q10. Having regard to the Review’s Terms of Reference, the ARC Act itself, the function, structure and operation of the ARC, and the current and potential role of the ARC in fostering excellent Australian research of global significance, do you have any other comments or suggestions?

Thank you once again for the opportunity to contribute to the Review of the Australian Research Council. We would welcome the opportunity to further discuss the issues raised in this submission, or more generally contribute our feedback on how the ARC can best function to support Australian research. Should you wish to discuss any issue we have raised, please contact the [Redacted]

Submission received

14 December 2022

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